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Government Relations Comment Letters
Current Comment Letters | Archive
2008
5/02/08
Comment Letter to FASB Director of Technical Application and Implementation Activities Russel Golden on the proposed FASB Staff Position (FSP) to amend FASB Statement 132.
3/20/08
Comment Letter to SEC Chairman Christopher Cox on Credit Rating Agency Reform
3/6/08
Comment letter to the Financial Management Service on use of the Automated Clearing House (ACH) system by Federal agencies
2007
11/19/07
Comment Letter on File Number S7-20-07, Concept Release on Allowing U.S. Issuers to Prepare Statements in Accordance with International Financial Reporting Standards
10/01/07
Comment Letter on FAS-133 and IAS-39 Accounting for Derivative Instruments and Hedging Activities
8/29/07
Letter and Statement of Support for Fedwire/CHIPS wire transfer remittance information
7/24/07
Comment Letter to Department of Labor on Fee Disclosure
6/19/07
Letter to the Federal Reserve Bank of New York and The Clearing House in support of the STP820 standard for remittance information with wire transfers
6/13/07
Letter to the Senate Finance Committee on IRS "Greater of" Interpretation
3/14/07
Comment letter to the Federal Reserve Board on late-day Fedwire funds transfers
3/12/07
Comment letter to SEC regarding proposed rule "Oversight of the Credit rating Agencies Registered as Nationally Recognized Statistical Rating Organizations."
3/7/07
Comment letter to FASB regarding Accounting for Convertible Instruments that Require or Permit Partial Cash Settlement upon Conversion.
2/21/07
Comment letter to the Federal Reserve Bank of New York and The Clearing House in support of a standard format for remittance information with wire transfers.
2/21/07
Comment letter on the SEC's Interpretive Guidance for Management regarding its Evaluation of Internal Control over Financial Reporting and the PCAOB's An Audit of Internal Control Over Financial Reporting That is Integrated with an Audit of Financial Statements (AS 5).
2006
9/29/06
Comment letter to the Federal Reserve Board on the collection of NSF fees via EFT 9/14/06
Comments on Concept Release Concerning Management's Reports on Internal Control over Financial Reporting 8/16/06
AFP Comment Letter on Deposit Insurance Assessments 7/31/06
AFP Support of the Credit Rating Agency Reform Act of 2006 7/19/06
Comment letter to FASB regarding the FAS-95 and the definition of cash equivelants 5/31/06
Comment Letter to FASB on DB Pension and Other Postretirement Plans 5/1/06
Comment letter to the SEC on SOX 404 4/6/06
Comment letter to FASB on the Fair Value Option for Financial Assets and Financial Liabilities 3/10/06
Comment letter to the Federal Reserve Board on coverage of payroll card accounts under Regulation E 2/2/06
Comment letter to NACHA regarding proposed interim rule for back office conversion
2005
12/19/05
Comment letter to NACHA regarding proposed OFAC and Operator-Related Changes to the ACH Network 12/12/05
Comment letter to Richard Shelby, Chairman of the Senate Committee
on Banking, Housing and Urban Affairs, regarding the reform of the
nation's deposit insurance system
11/07/05
Comment letter to the FDIC regarding the deposit insurance coverage of funds subject to transfer or withdrawal through use of stored value cards 11/04/05
Comment to the Senate Banking Committee regarding the reauthorization
of the Commodity Futures Trading Commission
6/28/05
Comment letter to FASB regarding recent change in accounting for auction rate securities 6/22/05
Comment letter to NACHA regarding proposal requiring companies use their IRS Taxpayer Identification Number (TIN) in the Company Identification Field of their ACH files
6/07/05
Comment letter to SEC regarding proposed Definition of Nationally Recognized Statistical Rating Organization -
5/03/05
Comment letter to Jennifer Johnson, Secretary, Board of Governors of the Federal Reserve System, regarding Regulation CC
4/25/05
Comment letter to Sen. Michael Oxley regarding Regulation Q 4/25/05
Comment letter to Congressman Barney Frank regarding Regulation Q 4/25/05
Comment letter to Sen. Michael Oxley regarding deposit insurance 4/25/05
Comment letter to Sen. Michael Oxley regarding deposit insurance 1/25/05
CIEBA of AFP comment letter to SEC regarding proposed rule on Regulation NMS (National Market System)
2004
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12/10/04
Comment letter to the National Automated Clearing House (NACHA) regarding proposed provision addition to Network Return Entry Fees
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11/18/04
Comment letter to the Federal Reserve Board regarding proposed amendments
to Regulation E
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7/15/04
Comment letter to the FDIC regarding a rule that clarifies the
definition of "deposit" as it relates to stored value cards
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6/28/04
Comment letter to the FASB regarding an amendment of FASB Statements
No. 123 and 95
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3/12/04
Comment letter to the Federal Reserve regarding availability of funds and collection of checks
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2/6/04
CIEBA comment letter to SEC regarding proposed rule, Amendments to
Rules Governing Pricing of Mutual Fund Shares
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